Cass County v. Leech Lake Band of Chippewa Indians

Background

The dispute involved the Leech Lake Band, a federally recognized tribe in Minnesota, and Cass County, which assessed property taxes on parcels inside the Leech Lake Reservation. Those parcels were originally removed from tribal control under 19th‑century laws, sold by the Federal Government to non‑Indians, and later repurchased by the Band. The Band paid taxes under protest and sued to block collection. Lower courts split over whether repurchased land regained tax immunity.

Reasoning

The Court framed the question simply: can state and local governments tax reservation land that Congress previously made freely sellable and that was later bought back by a tribe? Relying on earlier cases, the Court explained that when Congress makes reservation land alienable, it has shown an unmistakable intent to allow state and local taxation. A tribe’s later repurchase does not automatically restore tax immunity. Instead, Congress provided a separate federal procedure—under the Indian Reorganization Act—for returning land to federal trust and tax exemption.

Real world impact

The practical result is that counties may collect ad valorem property taxes on such repurchased parcels unless the land is explicitly taken into federal trust under the statutory process. The Band had already used that trust process for some parcels; other parcels remain taxable until the Secretary of the Interior restores trust status.

Dissents or concurrances

The opinion does not describe a Supreme Court dissent or concurrence, though the appeals court had been divided earlier about whether alienability automatically allowed taxation.